Wolffish:
driven to near extinction by fishing, two obscure fish test the
will of Canadians to preserve indigenous species versus commercial interests

(As government
scientists offer
disinformation to the Minister of Fisheries and Oceans in their request to exempt
fishermen from legal prohibitions against causing further harm to the severely
“threatened” northern and spotted wolffish.)

Slow-growing and sedentary, this fish can reach over 4 feet in length
and 40 pounds in weight. Despite its bloated appearance, this is not a
fatty fish, but a watery one. Northern wolffish is also known as the
"jelly catfish" because of the unusually low protein and high water
content of its muscle. Unpalatable to most people, the northern wolffish
has had virtually no commercial value in Canada. It has stout "wolf-like"
teeth which it uses to crush the shells of molluscs. Caught as "by-catch"
in many commercial fisheries, the northern wolffish has experienced a 98%
decline in numbers since the late 1970's, and it has been listed as a
"threatened" species under Canada's Species at Risk Act (SARA). This provides a
degree of legal protection. Unfortunately, the confinement of northern wolffish to Newfoundland waters places this species at a more imminent
risk of extinction than the "endangered" Northern cod. To
what lengths should or will Canada go to save this "fat cat?"

The Spotted Wolffish
(Anarhichas minor)

Related
to the northern wolffish, but growing to a larger size and occupying a
slightly wider geographical range, the spotted wolffish has firm,
marketable flesh, and a tough skin suitable for tanning. It has therefore
been of some commercial value. Also known as the leopardfish or spotted
catfish, the abundance of this species has declined by 96% since the late
1970's. The spotted wolffish is also listed under SARA as "threatened."

How far do we bend wildlife
protection laws in Canada for commercial interests?

The Canadian Department of
Fisheries and Oceans (DFO) has asked you to grant permission for commercial
fishermen to continue to inflict “incidental harm” on two species of marine fish
that have been listed as “threatened” in Canada. The northern wolffish and the
spotted wolffish are caught as by-catch in various commercial fisheries in
Atlantic Canada, and, barring your permission to continue catching them, harming
either of these fish species or damaging their habitat is now legally prohibited
in Canada under the Species at Risk Act (SARA).

Followed to the letter of the
law, protecting these two fish species will unavoidably entail significant
economic losses for the fishing industry. In June, 2004, as the legal
requirement to protect these two threatened fish species came into full effect,
a short paper was written by DFO advising you that continued harm inflicted by
the fishing industry will “not threaten the survival and recovery” of northern
and spotted wolffish. (DFO, 2004, “Allowable harm Assessment for Spotted and
Northern Wolffish”)

Political
concerns appear to have trumped conservation concerns in this case. DFO has
chosen to minimize the extent to which populations of wolffish are depleted, and has tried to
create an impression that, although wolffish are doing very poorly in
Newfoundland waters, population components elsewhere in Atlantic Canada are
stable and reasonably healthy. However, this is not true. Scientific evidence
that directly contradicts this conclusion was omitted from DFO’s evaluation of
wolfish and from the advice given to you.

DFO (2004) has written,
regarding northern and spotted wolffish: “There is no evidence of a decline on
the Scotian Shelf or in the Gulf of St. Lawrence and the declines observed at
the centre of their distribution have ceased…(and, criticizing the scientific
analysis that led to SARA listing for wolffish)…The COSEWIC Reports did not
examine trends in other areas, namely the Gulf of St. Lawrence or the Scotian
Shelf/Bay of Fundy/Georges Bank, where the population indices have been stable.”
(COSEWIC is the committee on the status of endangered wildlife in Canada.)

Both of these species, but
especially the northern wolffish, are cold water fish that have essentially only
ever been found in Newfoundland waters. This scientific observation was made of
both northern and spotted wolffish: “in the western North Atlantic, it occurs in
any numbers only off northeast Newfoundland. Elsewhere in Canadian waters, the
species occurs only as an occasional stray.” (COSEWIC In Press (a) and (b))

Contrary to DFO’s recent
advice, significant declines in the populations of spotted and northern wolffish,
in the appearance of these “occasional strays,” have in fact been documented on
the Scotian Shelf and in the Gulf of St. Lawrence. Thirty years of bottom trawl
research surveys have been conducted by DFO on the Scotian Shelf. Well over 3000
trawl sets were done (1970 – 2000). A recent review of the accumulated data (Shackell
and Frank, 2003, in press) indicated that the northern wolffish appeared in a
total of only 12 of these trawl sets and the spotted wolffish in 14. Shackell
and Frank noted specifically that, over the time series, the northern wolffish “demonstrated a significant decreasing trend in area occupied” on the
Scotian Shelf. This is evidence of a decline in the presence of a rare fish,
rather than “stable population indices.”

Both the northern and spotted
wolffish have also experienced significant declines in the Gulf of St. Lawrence. “In
the northern Gulf of St. Lawrence, where the (northern) wolffish is much less
abundant (average no/tow over all years = 0.02), the overall population decline
has also been very great, 97% from 1983 to 1994.” (O’Dea and Haedrich, in press
(a)). An identical observation was made for the spotted wolffish, except that
the average no/tow over all years was marginally greater at 0.03 (O’Dea and
Haedrich, in press (b)). Both are rare fish, and disappearing.

Where are the wolffish?

"Canadian distribution of the Northern
Wolffish (shown in red)."

Map reproduced from SARA website on August
27, 2004. The distribution of this species is a key consideration for the
Minister of Fisheries and Oceans in his consideration of whether or not he
should issue a permit for continued "incidental harm" by fishermen. DFO
recently suggested that the northern wolffish has a more extensive
distribution than is supported by scientific data. Click on the following
link to check for current updates of this map.
http://www.speciesatrisk.gc.ca/search/speciesDetails_e.cfm?SpeciesID=667

(Note: The distribution map for spotted
wolffish on the SARA website looks identical to this one. Aug. 27/04)

There is therefore no reason
to offer reassurance to the Minister of Fisheries and Oceans that stable
populations of wolffish might exist on the Scotian Shelf or in the Gulf of St.
Lawrence. Further, it is disingenuous of DFO to suggest that “population indices
have been stable” for northern and spotted wolffish in the Bay of Fundy and on
Georges Bank, because neither of these species extends its range into those
areas (O’Dea and Haedrich, in press (a) and (b), COSEWIC in press (a) and (b),
Leim and Scott, 1966). Indices “stable” at zero, perhaps? A different but related
species of wolffish, the striped Atlantic wolffish (Anarhichas lupus), inhabits
the more southern waters of the Bay of Fundy and Georges Bank. This species of
wolffish is also in a “severely depleted” condition, in both Canadian and
American waters, and the Atlantic wolffish has been designated as a species of “special concern” in
Canada (DFO, 2000, Mayo, 2000). All species of wolffish in the northwest
Atlantic have declined sharply in recent years, as have all large
bottom-dwelling fish as a group, (this has been clearly documented on
the Scotian Shelf (DFO, 2003, Choi et al, 2004)), leaving no reason to think
that a few peripheral elements of the northern and spotted wolffish populations
might be doing well anywhere in Canadian waters. However, this seems to be the
idea that DFO is trying to float to the Minister of Fisheries and Oceans in its
request for a permit for ongoing harm to the species by the fishing industry.

DFO has advised you this
summer that “Between the late 1970’s and early 1990’s, the abundance of northern
wolffish and spotted wolffish had declined by over 90% on the Grand Banks and
Northeast Newfoundland/Labrador Shelf.” A decline of “over 90%” might suggest to
you that perhaps nearly 10% of the original fish numbers remain. But the loss
has been substantially greater than this, and relevant data extends past the
early 1990’s. A scientific assessment in 2001, for instance, indicated for
northern wolffish that “since 1978, abundance in the primary range off northeast
Newfoundland is down by 98%. Numbers have declined steadily, the number of
locations where the species occurs has declined, and the range may be
shrinking.” (COSEWIC in press (a)). Similarly, the spotted wolfish is “down by
96%.” (COSEWIC in press (b))

By choosing to discuss only
trends in “abundance,” DFO has failed to alert you to another serious indicator
of decline in the wolffish populations: the average size of both northern and
spotted wolffish has declined significantly over recent decades. The implied
accelerated disappearance of large adult fish is widely recognized by scientists
as a serious negative signal when it affects fish stocks, and this pattern has
been generally associated with “over-exploitation.” But DFO has written, as
“Rationale for Permitting”: “Given the steady state of the northern wolffish
population trajectory and the increasing trajectory for spotted wolffish over
the past 12 years, current levels of mortality do not appear to be negatively
affecting the survival of the species.” This statement, however, is contradicted
by the recent declining size of both wolfish species; whether they are
succumbing as fishermen’s by-catch or to “natural” causes. Declining fish size is
a cardinal signal of rising mortality, therefore the “current level of
mortality” does indeed appear to be negatively affecting wolffish.

There seems to be substantial
disagreement regarding the status of northern and spotted wolffish between DFO
and the authors of the COSEWIC status report. This may help to explain the lack
of distribution maps for these species on the SARA website. One of the COSEWIC
report authors is Dr. Richard Haedrich, a well-respected, senior professor of Ocean Studies at Memorial
University of Newfoundland. A consultation with Dr. Haedrich might provide you
with a more complete view of the status of wolffish. Haedrich has argued that
both northern and spotted wolffish qualify for the more urgent SARA designation
of “endangered,” rather than “threatened” species, and he has advised “when in
doubt, err on the side of the fish.”

Mr. Regan, DFO has asked
your permission to allow continued harm to wolffish, not because the fish
populations are stable, but because application of the SARA prohibitions will
have a severe negative economic impact on the fishing industry.

“…northern and spotted wolffish…are captured in
virtually every demersal fishery (about 35 directed species) in the Canadian
Atlantic and Davis Strait. They are captured in various types of trawls, in
gillnets, on longlines and in traps. There is little evidence of seasonality to
the catches, thus, the only alternative would be fishery closures. Detailed
economic analyses are not required to demonstrate that closures of Atlantic demersal fisheries would adversely affect the Atlantic economy and the
livelihood of thousands.” (DFO, 2004)

Canada may choose to place a
higher value on the “livelihood of thousands” than on the survival of each and
every indigenous species, and relatively obscure animals like the wolffish might
therefore be knowingly sacrificed for this reason. Is this happening now? This
strategy contravenes current federal law, but if this is what DFO and the
fishing industry feel they must do, then why not openly admit it? Perhaps this
course of action is reasonable, perhaps it is not, but to pretend to be doing
something else is wrong. It seems now that taxpayers are funding federal
scientists to find ways to avoid complying with the law. Perhaps Canadians
should be asked if they would prefer to have the SARA law changed?

The “livelihood of thousands”
in the Atlantic fisheries now depends largely on harvesting crustaceans; shrimp,
crab and lobster. And the persistent quibbling over one fish at a time serves
effectively to avoid focusing our thoughts on the profound level of change that
we have inflicted on the ocean ecosystem itself by centuries of fishing (Choi et
al, 2004, DFO, 2003). At this point, a more realistic assessment of the future
prospects of wolffish, all other large finfish, fishermen and crustaceans, might
be that the cumulative effects of fishing have subtly eroded the strength of the
living ocean web to the point where it has now fallen below the level where
large finfish can be widely supported. To continue working, fishermen in
Atlantic Canada now need to take predominantly crustaceans. Populations of
crustaceans will be supported for some time yet, but their substantial harvest
entails lowering ocean system vitality further. Therefore, the period of
profitable crustacean harvesting will ultimately be limited, as was that for
fish (however, the time will be much shorter for crustaceans). Remnant fish
populations will continue to decline and disappear during the years of heavy
crustacean harvesting, so the preservation and “recovery” of individual finfish
species during this time is unrealistic.

Signs of stress and decline
are now seen in the crustaceans that currently support the Atlantic Canadian
fishing industry, in shrimp, crab and lobster. This you already know. Fisheries
are in a “post-groundfish” phase now, and will shift at some future time to a
“post-crustacean” phase. Unfortunately, however, this will not mean a resurgence
of the groundfish, as some people believe it will, because the changes to the
ocean system have included a lowering of overall food production below the point
where such fish can thrive. Unthinkable? Maybe, but as I have told you before,
broad, unmistakable signals of this fundamental productivity decline are
evident throughout the ocean today. And fishing can reasonably be implicated as
a cause. The failure of fisheries science to predict this ominous complication
has not prevented its occurrence, but it seems to have stymied efforts to
understand what is happening.

Rather than a “cod recovery
plan” or a “wolffish recovery plan,” or any other single-species conservation
initiative, we urgently need a more determined and comprehensive “ocean
ecosystem recovery plan.” This will be more difficult in some ways, but simpler
in others. Scientists today need to visualize our approach to ocean life as a
salvage operation, as providing “intensive care” for a living entity that has been seriously damaged, rather than blindly persisting in seeking
new ways to drain ever more protein from a disabled food web. This concept is
naturally anathema to fishing interests, so DFO will be unable to grapple with
it. But this is where SARA might help…if DFO is not permitted to sidestep the
law. Regardless, nature will continue to function according to her own
rules, and she will not be forced into the “sustainable fishing” box that we
have created for our psychological comfort. We can choose to remove the blinders, or we can leave
them on, but people will soon be forced to see the bitter truth that we simply
cannot have our fish and eat them too – not indefinitely. Commercial fishing has
now pushed the bigger fish into the endgame, and it is impossible to
“facilitate” the recovery of species like wolffish and cod while continuing to
prosecute other fisheries.

Mr. Regan, I suggest that the
time for Canadians to bite the bullet is now, before a multitude of larger
marine animal species are lost irretrievably from our waters. This might
realistically happen in the near future, and with surprising speed, but there is
still a chance that we might be able to take preventative action. Something
needs to jam the gears of destruction, and it might as well be the otherwise
“useless” wolffish. Refuse DFO’s request for the “permit” because they provided
you with misleading advice, and because the wolffish do, in fact, qualify for
legal protection in Canada at this time. (These fish need a good lawyer…)

Challenge DFO to begin to
take an honest “precautionary, ecosystem approach” when setting measures to
conserve marine life, and more importantly, challenge them to admit how many
puzzle pieces they have today that they cannot fit into the mould they started
out with, into the “sustainable fishing” box. Challenge – or perhaps “allow” -
DFO scientists to act with a level of “precaution” that reflects the
many fundamental aspects of the marine ecosystem that they do not understand.
Many of DFO’s decisions, such the recent call for the wolffish permit, are
heavily distorted by a short-term, pro-industry bias, and this must make a
difficult work environment for true scientists.

Organizing an inquiry into the
irregularities plaguing DFO Science would be appropriate, as would your reinstating
something along the lines of the former Minister’s Advisory Council on Oceans.